Where FTC enforcement stands today
The FTC’s CARS Rule was vacated by the Fifth Circuit in January 2025 and formally withdrawn in February 2026. Enforcement never slowed. The FTC kept bringing deceptive-pricing cases under Section 5 of the FTC Act, and 2026 made the playbook clear.
On April 2, 2026, the FTC and the Maryland Attorney General settled with Lindsay Automotive Group over advertised prices that didn’t hold up in the showroom. Lindsay will pay a $3.1 million civil penalty to the Maryland Attorney General’s office, and consumers who were charged by the dealer group a total of more than $75 million in connection with vehicle purchases between April 2020 and December 2025 may be eligible for refunds. The refund formula is the part every dealer should read: eligible consumers are to be reimbursed for the difference between the advertised price and the price paid, as well as for add-on products or services they did not agree to purchase. The order also requires the total price, clearly and conspicuously, as the most prominently displayed item in any visual disclosure.
The same week, the FTC sent warning letters to 97 dealer groups covering more than 1,000 locations nationwide. The letters name five practices: advertised prices that depend on rebates not everyone qualifies for, prices that omit a required down payment, prices available only with dealer financing, required add-ons not in the advertised price, and advertising vehicles that aren’t available.
Why the letters matter: the FTC generally can’t fine a dealer for a first Section 5 violation. It can seek civil penalties against a company that knew its conduct violated the FTC Act, and a formal notice is how it establishes that knowledge. Penalties run up to $53,088 per violation. What you knew, when you knew it, and what you did about it is now the question.
States are writing the standard into their own law. California’s CARS Act (SB 766) took effect October 1, 2026: a legally defined “total price” on any advertisement or listing that references a specific vehicle, the same price in the dealer’s first written reply to a customer about that vehicle, and records showing compliance for two years from the date the record is created. State UDAP statutes give every attorney general the same reach, and Maryland just showed they’ll use it alongside the FTC.
The practical result: the obligations didn’t disappear with the rule. They come from every direction, and they apply to every channel you advertise on: listing pages, offers pages, and every Meta ad.
The compliance checklist
Advertise a price a buyer can actually pay.
No rebates most buyers can’t get, no mandatory fees or add-ons left out, no price that requires dealer financing.
Include the disclosures a payment triggers.
Advertising a monthly payment or APR triggers specific federal disclosures for credit and lease ads. State what’s due at signing. In California, include the total of payments.
Get express, informed consent for add-ons.
No charge for GAP, service contracts, protection products, or etch without the buyer’s clear authorization for that specific charge.
Don’t charge for add-ons that provide no benefit.
Regulators have cited products like nitrogen tire fills that contain no more nitrogen than regular air.
Make disclosures clear and conspicuous.
Same medium as the claim, unavoidable, not hidden behind a hover or a click, on every listing page, digital ad, and social post.
Pull sold vehicles fast.
Advertising a vehicle you no longer have is on the FTC’s list.
Keep the record.
What each page and ad said, when you reviewed it, and what you changed. California requires two years. The FTC’s penalty authority turns on what you knew. A dated record is how you show diligence.
The practices regulators cite most
- Advertised price depends on rebates or discounts not everyone qualifies for
- Advertised price omits a required additional down payment
- Advertised price available only with dealer financing
- Buyer required to purchase add-ons not in the advertised price
- Advertising vehicles that are unavailable or don’t exist
- And in our own captures of dealer Meta ads: a payment advertised with none of the terms that go with it
Keeping the record
The hard part isn’t knowing the rules. It’s being able to show, months or years later, what a page or ad said, when you looked at it, and what you did. The Lindsay refunds were calculated from advertised price versus price paid across five years. The FTC’s penalty authority turns on what you knew and when. California now requires two years of records. None of that is answered by an opinion about compliance. It’s answered by a dated record.
Radar by Auto AI™ captures your offers pages, site-wide disclaimer, a sample of your listing pages, and every live Meta ad twice a week. Each capture is saved with the date and a cryptographic hash. Radar pulls out the figures and the fine print and asks the questions a reviewer would ask; your answers and fixes go into a dated Record in your name. One click exports an Evidence Pack for any window up to two years. On Growth and Max, the Market File shows what competitors are advertising and the price their own fine print adds up to. No DMS, no IT project.
Radar doesn’t decide whether an ad complies. You and your counsel do. Radar makes sure you can show what you decided.
Radar by Auto AI™
Know what you advertised. Show what you did about it.
Your website and Meta ads captured twice a week, a dated record of your decisions, and an Evidence Pack when someone asks. From $299/month per rooftop.
This guide is informational and not legal advice. Consult counsel for your dealership's specific obligations.
Last updated November 3, 2026.